That is a good question.
It is difficult to know whether there really is a problem because this is not something that is currently being measured. The association does not report to us. There is no report on this, and we are not doing anything in that area. Based on the available information, we cannot be sure. Anecdotally, it is certain that, if there are ATMs at certain locations, there is reason to believe they could be used for nefarious purposes. A problem probably exists.
That is just another way to launder money. Money can be laundered through an ATM. We are not provided with a registry as such. We don't know who the owners are, we don't know where the money that goes into those machines comes from and we don't know who is withdrawing the money. Is that a way to launder money? Definitely.
It is difficult for us to provide a recommendation. This issue is raised in the document published by the Department of Finance. Other issues are also raised in that document.
Could a recommendation put an end to the use of ATMs to launder money? I am not sure. Since a solution is difficult to find, I invite you to be very creative.
The issue also involved compliance. What can be done? Who should support the compliance regime? Is it the owner or the actual location? Is there a real owner? It is difficult to answer those questions.
ATMs are indeed a way to launder money. Is that the most important issue? I don't know.
I will let you decide whether a recommendation should be made in that respect.